The Association Sunce comments on the “Marjan Park-Forest Management Plan 2022-2032” draft within the process of public insight

The public institution for the management of the Marjan – Forest Park developed the Management Plan proposal (2022-2032) as a strategic document of the institution, which was available for public insight  in the period from January 20 to February 19, 2022. The Association for Nature, Environment and Sustainable Development Sunce supports the development and future implementation of the Management Plan with the aim to preserve the forest and improve protected area management based on the Nature Protection Act. During the public insight  period, the Association Sunce submitted its suggestions, opinions, and comments for further improvement of the proposed Plan.

The Association Sunce consider that the Management Plan is not fully aligned with the Guidelines for Planning of the Management of Protected Areas and/or Ecological Network Areas (Ministry of Economy and Sustainable Development, 2020.) and examples of good practice. In the protected area context, the term participatory governance means that stakeholders are involved in different ways in different phases of the protected area’s management cycle. A public institution cannot ensure the long-term protection of the natural values without the understanding, support and involvement of the local community. The Association Sunce believes that stakeholders were not adequately involved in the process of Management Plan development, and within the document it is not possible to conclude what were their views and opinions. Only one organized stakeholders’ workshop is not enough to implement a quality consultation process, especially  since the area is being intensively used by citizens, various institutions and organizations, there are numerous problems and conflicts present, and it is located in the second largest city in Croatia and therefore very important for a large number of stakeholders. More attention within the Plan should be put on issues related to housing, construction, and utility infrastructure in Marjan – Forest Park since these are factors that significantly affect the sustainability of the management of this area.

Furthermore, since the ownership structure of the forest is not regulated, but affects a lot its management and financing commitment , we believe that solving ownership issues in the initial years of Management Plan implementation is essential for its complete realization. The Plan foresees the purchase of agricultural land to preserve grasslands, but there is no estimation of surface area, location, and parameters that would show how the Public Institution plans to spend money on this activity. The question is who will be registered as the owner and pay the purchase price if the ownership of the existing “public” land is still questionable (the City of Split or the Republic of Croatia).

The implementation of the activities within the Plan should address identified pressures and threats and thus contribute to the achievement of management goals. We consider that most of the planned activities are not explained sufficiently detailed and clear, and it is very difficult to understand with what every single activity is specifically dealing with. For example, it is not clear whether the adrenaline park, zip line and paint-ball field are being planned  within activities related to the visitor infrastructure, which additionally argues our previous comment. We would also like to emphasize that the Association Sunce doesn’t support the construction of these facilities in the protected Forest Park. The financial part of the Plan is the assessment of its implementation costs  for the purpose of better and more realistic planning, but also for the understanding of Management Plan. When determining finances, it is also necessary to predict the increase of human resources. But this Plan, says very little about investment direction for the next 10 years. Considering there is no specific information about the annual income and outcome of the Public Institution, it is impossible to put stated amounts into any context to assess the reality of the future implementation of this Management Plan. Also, there is a lack of data about employees per workplace and organizational unit, an overview of real estate and movable owned by the Public Institution. Without this data, it is not possible to evaluate whether the Plan is realistically set and in accordance with the capacities. The management plan is also used to increase the transparency of the Public Institution, therefore we consider it is important that the public has insight into its operations and capacities.

We hope that the Public Institution will improve the draft of the Management Plan in accordance with  the national Guidelines and comments from the public insight, and that it will be officially adopted as soon as possible. This strategic document   is the basis for improving the transparency and efficiency of the Marjan – Forest Park management , a green oasis and the lungs of the city of Split.